>Assess whether your multinational group meets the €750M revenue threshold for Pillar Two — initiate local top-up tax analysis for Vietnamese entities by Q1 2024
>Submit 2023 transfer pricing documentation (including master file, local file, and CbCR notification) to GDT by 30 June 2024 per Decree 132/2020/ND-CP
>Issue all B2B invoices exclusively via GDT’s Electronic Invoice Database System (launched May 2023); non-compliant invoices are invalid for VAT deduction
English Summary
Vietnam’s General Department of Taxation (GDT) is advancing implementation of the OECD/G20 BEPS 2.0 framework, with emphasis on Actions 5, 6, 7, and 13. As of September 2023, Vietnam is evaluating efficient models for applying the 15% global minimum tax (Pillar Two). Electronic invoice database analytics launched in May 2023 strengthens real-time transfer pricing oversight. Multinationals with Vietnamese subsidiaries must prepare for mandatory Country-by-Country Reporting (CbCR) likely effective from 2024; maintain contemporaneous transfer pricing documentation per Decree 132/2020/ND-CP; and assess Pillar Two exposure if consolidated revenue exceeds €750 million. Non-compliance may trigger penalties up to 20% of underpaid tax plus interest. Foreign enterprises should engage local tax advisors by Q1 2024 to align policies with upcoming Circulars expected from GDT.
General Department Of Taxation - Ministry Of Finance - Danh sách tin Trang chủ Internet Home About Us News Documents Tax Treaty Organization Structure | Address of Tax OfficesTax Policy | OthersAgreements for Avoidance of Double Taxation | Double Taxation TreatyTax Policy | Others Web Content Viewer BEPS Action Plan Explanatory Statement of OECD/G20 Base Erosion and Profit Shifting Project (21/02/2017) Brief introduction of BEPS Project and Overview of the package of 15 BEPS Action Plan Executive Summaries of OECD/G20 Base Erosion and Profit Shifting Project (21/02/2017) Preliminary explantory of each BEPS issues and BEPS's impact in 15 Actions; the solutions of BEPS project are given. Action 1: 2015 Final Report of OECD/G20 Base Erosion and Profit Shifting Project (21/02/2017) Addressing the Tax Challenges of the Digital Economy Action 2: 2015 Final Report of OECD/G20 Base Erosion and Profit Shifting Project (21/02/2017) Neutralising the Effects of Hybrid Mismatch Arrangements Action 3: 2015 Final Report of OECD/G20 Base Erosion and Profit Shifting Project (21/02/2017) Designing Effective Controlled Foreign Company Rules Action 4: 2015 Final Report of OECD/G20 Base Erosion and Profit Shifting Project (21/02/2017) Limiting Base Erosion Involving Interest Deductions and Other Financial Payments Action 5: 2015 Final Report of OECD/G20 Base Erosion and Profit Shifting Project (21/02/2017) Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance Action 6: 2015 Final Report of OECD/G20 Base Erosion and Profit Shifting Project (21/02/2017) Preventing the Granting of Treaty Benefits in Inappropriate Circumstances Action 7: 2015 Final Report of OECD/G20 Base Erosion and Profit Shifting Project (21/02/2017) Preventing the Artificial Avoidance of Permanent Establishment Status Action 8-10: 2015 Final Report of OECD/G20 Base Erosion and Profit Shifting Project (21/02/2017) Aligning Transfer Pricing Outcomes with Value Creation Page | 1 | 2 | > | >> | Top Z7_049IL8VSOJ9OE0IUE751KH1A40 News Application of global minimum tax: which solutions are efficient for Vietnam? (22/09/2023) A comprehensive reform of administrative procedures toward being modern (29/05/2023) The system of electronic invoice database analysis and management: a new step forward in modernizing and reforming of the tax administration (29/05/2023) Policies take effect from February (01/02/2023) The 2022 state budget-finance picture: many bright points recognized (17/01/2023) More Web Content Viewer Home Sitemap Hot line Unicode Font Contact Website of the General Department of Taxation Line Organisation: Ministry of Finance - License for establishment of website on Internet: No.207/GP-BC, dated May, 14th 2004, issued by the Press Department of Ministry of Culture and Information Address: 123 Lo Duc St., Hanoi, Vietnam Telephone: (024) 39712555 | Fax: (024) 39712286